PRIVACY POLICY

Birthright Israel International (Taglit) and Birthright Israel North America (collectively, “Birthright Israel,” “we”, “us”, and “our”) is committed to protecting your privacy when you use the Birthright Israel website www.birthrightisrael.com (the “Site”). When you access, browse, or use the Site, including but not limited to when you register for one of our activities, information will be collected, transferred, processed, stored, and disclosed in accordance with this privacy policy (“Policy”). This Policy governs the information collection and disclosure practices for the Site. By accessing, browsing, or using the Site, you expressly consent to the collection, transfer, use, processing, and storage of your information (including personally identifiable information), as described in this Policy.

IF YOU DO NOT AGREE WITH THIS POLICY OR THE INFORMATION COLLECTION, USE, AND DISCLOSURE PRACTICES DESCRIBED IN THIS POLICY, DO NOT USE THE SITE OR CLICK TO INDICATE THAT YOU AGREE TO THESE TERMS WHEN SUCH CONSENT IS REQUESTED.

1. Information Collection Practices

1.1. Information that You Provide

1.1.1. Birthright Israel Website Registration/Trip Application – When registering on the Site and when completing an application to participate in the Birthright Israel program, you will be asked to provide personally identifiable information, such as, but not limited to, your full name, date of birth, passport number, email address, telephone number, address, the names and contact information for third parties (such as a parent/guardian), and other information related to your background and religious affiliation. You may also be asked to provide health information as needed in consideration of the activities taking place on your trip.

1.1.1.1. Registration Through Social Sites – Rather than entering information directly on the Site in order to register, we provide the option to register by utilizing your credentials on a Social Site (such as a Facebook). When you provide credentials for a Social Site via our Site, we may use those credentials to obtain information about you from that Social Site and the Social Site may automatically track your activities within our Site.

1.1.2. Deposit/Payment Processing – At the end of the application process, you will be asked to pay a deposit – and for certain trips, you will be asked to make a payment – and will be redirected to a third-party payment site (the “Payment Processor”). The Payment Processor may ask you for your name, billing address, shipping address, credit card information, and related information. While Birthright Israel will not have access to nor collect your credit card information – e.g., credit card number, expiration date, security code (“Additional Credit Card Information”), it will collect, from the Payment Processor, the other information you have provided, as well as a transaction ID number (the “Transaction Information”). See Section 4 (Third Party Providers) for more information about third party provides, including the Payment Processor. Please make sure to review the privacy policy of the Payment Processor to better understand what information they collect and how that information is stored, used, and shared.

1.1.3. Information You Provide to Trip Organizers – After completing the application process on the Site, you may be redirected to the site of the Birthright Israel Trip Organizer who is responsible for running the Birthright Israel trip you have selected (the “Trip Organizer”), or you may, at a later date, receive an email from the Trip Organizer or a link to the Trip Organizer’s site asking you to provide additional relevant information needed by the Trip Organizer. We will not collect information that you provide to a Trip Organizer, whether via their website or through a questionnaire completed via email. Please remember that any information you provide to a Trip Organizer will be governed by that Trip Organizer’s privacy policies and storage and processing of such information is the sole responsibility of the Trip Organizer.

1.2. Automatically Collected Information – In addition to the above, we will automatically collect some information about you when you use the Site. In general, when using the Site, all information collected about you and your use of the Site constitutes personally identifiable information; this information may include, but will not be limited to, your diagnostic log information, IP address, operating system and language, referring/exit pages and URLs, browsing history, number of clicks, landing pages, cookie information, the pages you requested and viewed, the amount of time spent on particular pages, what questions you have answered in a Birthright Israel trip application, and the date and time. We collect this information for the purposes described in this Policy, including to better understand our constituent base and to improve the quality of the Site.

1.2.1. Cookies – A cookie is a small text file that is stored on a user’s computer. Our third-party analytics provider uses cookies to record information about your activities when you use the Site in order to “remember” you when you return to the Site. Some cookies remain on your device until you delete them. Others expire when you leave the Site. You may set your browser setting to attempt to reject cookies, but if you do so you will not be able to use the Site. See the section “Do-Not Track Settings” below for more information on how the Site may respond to your browser settings. We do not control the use of cookies by third parties. See Section 4 (Third Party Providers) for more information and review the privacy policies of all third-party service providers for more information on third-party cookies.

1.2.2. Pixels – Pixels are tiny graphics with unique identifiers that are used to track the online movements of web users. Unlike cookies, which are stored on a user’s computer hard drive, pixels are small graphics that are about the size of the period at the end of the sentence that are embedded invisibly on Site pages. Our third-party analytics provider may place pixels on Site pages that track what other websites you visit (both before and after visiting the Site). Our third-party analytics provider uses information obtained from pixels to help us improve our business and the Site. We do not control the use of pixels by third parties. See Section 4 (Third Party Providers) for more information and review the privacy policies of each of third-party service providers for more information on third-party pixels.

2. Information Use Practices by Birthright Israel

2.1. General – We may use any personally identifiable information you provide or which we have obtained about you in accordance with this Policy (including tracking information) to: i) enable you to participate in the Birthright Israel program; ii) operate, maintain, and improve the Site (including providing you a more personal experience); iii) communicate with you; iv) provide you information about products and services (including products and services of third parties); v) market to you; vi) troubleshoot; vii) conduct research; viii) resolve disputes; ix) collect fees owed; x) detect and protect against errors, fraud, and criminal activity; xi) assist law enforcement; xii) enforce this Policy and any other terms or conditions related to the Site; and xiii) any other purpose described in this Policy or that we describe to you at the time of collection.

2.2. Deposits/Payments – As noted, all Birthright Israel trip deposits/payments are processed by a third-party Payment Processor. Such Payment Processor will collect and use information that you provide, including Transaction Information and Additional Credit Card Information, in order to appropriately process your deposit/payment. As noted, Birthright Israel collects and stores certain of your personally identifiable information and your Transaction Information, for all deposits/payments; however, Birthright Israel will not have access to your Additional Credit Card Information and will therefore not collect, store, or use it in any way. Birthright Israel may use the Transaction Information it collects and stores for certain purposes including but not limited to, responding to inquiries regarding deposits/payments, processing refunds/donations, ensuring the consistency and efficiency of deposit/payment processing, and related troubleshooting and customer service purposes.

2.3. Communications – We may use any personally identifiable information you provide or which we have obtained about you in accordance with this Policy to send you emails or other communications related to the Birthright Israel program or the Site, or in response to your inquiries or requests. You may not opt-out of receiving service-related messages that are not promotional in nature prior to your trip. We may also send you marketing emails, surveys, or newsletters to notify you about products or services that may be of interest to you. If you would like to stop receiving marketing emails from us, please click on the unsubscribe link at the bottom of any marketing email you receive. If you opt-out, you will only continue to receive service-related emails.

2.4. Anonymizing Information – We may use conglomerated personally identifying information in an anonymized way for any lawful purpose, including analyzing trends, research, Site administration, tracking movement around the Site, and to improve our business and the Site.

2.5. Retaining Your Information – In general, we will retain the information provided by you or which we obtained about you in accordance with this Policy, indefinitely, or as long as legally required or allowed. In particular, we may retain and store information provided by you or which we obtained about you for the longer of: (i) the time necessary to provide our services to participants and/or alumnae; and (ii) the amount of time required or recommended by law. Birthright Israel may associate or link information provided by you or obtained about you in accordance with this Policy to other information or records we separately have in our possession.

3. Information Sharing

3.1. Generally – We will not sell or rent any of your personal information to third parties for marketing purposes. However, we may disclose your information to affiliated and related entities or organizations, partners, other not-for-profit entities, and to agents and service providers (e.g., airlines), for any purpose, particularly as needed to enable you to participate in the Birthright Israel program and/or for other purposes that implement or complement our educational goals. We may also share non-personally identifiable information with third parties for any lawful purpose, including analyzing trends, research, Site administration, tracking users’ movements around the Site, and to improve our business, products, services, and the Site. Use of information by affiliated and related entities and organizations, as well as by partners and other not-for-profit entities, will be subject to this Policy or an agreement that is at least as restrictive as this Policy. For information on use of information by Payment Processors, agents, and service providers see Section 4 (Third-Party Providers).

3.2. Legal Requirements – In some cases, we may disclose your personally identifiable information: i) as required by law; ii) if we believe that disclosure is needed to protect our rights; iii) to government regulators; iv) to law enforcement authorities; v) in connection with any judicial proceeding, court order, subpoena, or legal process served on us or the Site; vii) to address health needs; and viii) to respond to a physical threat to you or another person.

3.3. Insolvency and Business Transitions – If we ever file for bankruptcy or engage in a business transition such as a merger with another company, or if we purchase, sell, or reorganize all or a part of the Site or our business or assets, we may disclose your personally identifiable and non-personally identifiable information, including to prospective or actual purchasers, in connection with one of these transactions. Any successor entity may become entitled to all of the personally identifiable and non-personally identifiable information about you that we have stored.

3.4. Social Sites – Certain Site features may permit you to log-in using your Social Site credentials and permit you to share information and content with Social Sites. When you choose to log-in through a Social Site, the Social Site may track your actions on our Site and collect related information about you. Additionally, when you share with a Social Site, we may share that information or content as well as additional personal information about you with the Social Site. The Social Site’s tracking of your actions on our Site and the information you choose to share through a Social Site is all subject to that Social Site’s privacy policy and practices; you should therefore familiarize yourself with the Social Site’s privacy policy and practices before using your Social Site credentials to log into our Site and before you choose to share anything through the Social Site.

3.5. Disclaimer – We cannot ensure that all of your personally identifiable information will never be disclosed in ways not otherwise described in this Policy since no transmission of data over the Internet can be 100% secure. You affirm your understanding that this is the case.

4. Third-Party Providers –– We engage and work with certain third parties to help us operate and improve the Site and to implement and enable you to participate in the Birthright Israel program. Depending on the nature of the third party, we may: i) directly share with such third party information we collect about you (such as an airline, when needing to book a flight to Israel in connection with your participation in the Birthright Israel program); ii) automatically redirect you or provide links to a third party site to enable you to directly provide such third party with additional information (such as with Payment Processors and Trip Organizers); iii) incorporate integrated tools that allow you to share your actions, information, or content via a Social Site; or iv) incorporate tools that allow select third parties – namely, Social Sites and Analytics Providers, as later defined herein – to directly collect information from you and about your use of the Site. The collection, use, and sharing of any information collected from you and directly provided by us to any third party, or directly collected on our Site by a Social Site or an Analytics Provider, will be governed by this Policy unless otherwise noted. Please remember that, unless otherwise noted, we do not control information collected by third parties where you have chosen to provide such information to them, and are therefore not responsible for their collection, use, or sharing of that information. Please review their privacy policies for more information on third party information collection, use, and sharing practices.

4.1. Analytics Providers – We use third-party Analytics Providers (such as Google) to collect information about Site usage and about Site users, including demographic and interest-level information. Analytics Providers use cookies and pixel in order to collect demographic and interest-level information and usage information from users of the Site, including information about the pages viewed, time spent, browser, operating system, and IP address. Cookies and pixels allow the Analytics Providers to recognize when a user visits the Site and when the user exits the Site to explore another website or Social Site. The Analytics Providers use the information they collect from the Site and other websites to share, with us and other website operators, information about users, including age range, gender, geographic regions, general interests, and details about devices used to visit websites and purchase items. We do not link information we receive from Analytics Providers with any of your personally identifiable information. For more information regarding Google’s use of cookies, pixels, and collection and use of information, see the Google Privacy Policy (https://www.google.com/policies/privacy/). If you would like to opt out of Google Analytics tracking, please visit the following link: Google Analytics Opt-out Browser Add-on (https://support.google.com/analytics/answer/181881?hl=en).

5. Online Tracking and your Choices – As discussed above, because we, the Social Sites you may choose to log into our Site through, and our Analytics Providers, automatically collect Site usage information through the use of cookies, pixels, and other tracking technologies (including as described in the “Automatically Collected Information” section above, and elsewhere in this Policy), your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of automatically collected information. One way to attempt to “opt-out” of the collection of any information through cookies and some (but not all) other tracking technology is to actively manage the settings on your browser to delete and disable cookies and other tracking/recording tools. However, getting a “Do Not Track” signal to work as you might want is difficult and may not be possible. Using browsers as an example, not all tracking technologies can be controlled by browsers; unique aspects of your browser might be recognizable even if you disable a tracking technology; not all settings will necessarily last or be effective; even if a setting is effective for one purpose data still may be collected for another; and even if one website observes a “Do Not Track” signal, that website usually will not be able to control other websites.

6. Information Security Measures – Keeping secure personal information that we collect is of great concern to us. Birthright Israel maintains: i) appropriate and reasonable physical, electronic, and managerial procedures; ii) commercially appropriate and reasonable storage mechanisms (including backup, archive, and redundant data storage, on-site and off-site); and iii) appropriate and reasonable precautions, in order to safeguard and secure Site user information as collected and stored, and to prevent the disclosure to, and loss or alteration of, any such information by unauthorized third parties. Birthright Israel also endeavors to reasonably ensure that any party with which it shares your information, as permitted by this Policy, also employs similar procedures, mechanisms, and precautions. However, no Internet or mobile transmission is ever fully secure or error free and therefore Birthright Israel cannot guarantee that your information will not be accessed, deleted, or altered by an unauthorized third party, neither while it is in Birthright Israel’s sole control nor in the event it has been shared as permitted under this Policy. Because most Internet and mobile transmissions are not encrypted, you should take special care in deciding what information you send via the Internet or other mobile transmission and that when you provide such information, it is at your own risk.

7. Children – The Site is Not for or Directed Towards Children. The Site is not intended for anyone under the age of 16, and we do not intend to and will not knowingly collect any personal information from children under the age of 13. Children under the age of 13 are prohibited from using the Site. If we learn that we have collected information from a child under the age of 13, we will remove that information immediately and delete it from our servers (subject to applicable law and this Policy). If you believe content from a child under the age of 13 has been posted to the Site, please notify us by contacting us at information@birthrightisrael.com.

8. California Shine the Light Law – California Civil Code Section 1798.83 permits California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed personal information (as defined under that statute) of that California resident, for direct marketing purposes, in the preceding calendar year, and the categories of that kind of personal information that was disclosed to them. If you are a California resident and you wish to make such a request you may contact us by using the contact information in the Privacy Questions section at the bottom of this Policy.

9. California Minors – If you are a California resident who is under age 18 and you are unable to remove publicly-available content that you have submitted to us, you may request removal by contacting us at: information@birthrightisrael.com. When requesting removal, you must be specific about the information you want removed and provide us with specific information, such as the URL for each page where the information is located, so that we can find it. We are not required to remove any content or information that: (1) federal or state law requires us or a third party to maintain; (2) was not posted by you; (3) is anonymized so that you cannot be identified; (4) you don’t follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the Content or information. Removal of your content or information from the Site does not ensure complete or comprehensive removal of that content or information from our systems or the systems of our service providers. We are not required to delete the content or information posted by you; our obligations under California law are satisfied so long as we anonymize the content or information or render it invisible to other users and the public.

10. European Nationals – If you are a European national, the collection, storage, and retention of your information may also be subject to the provisions of the European General Protection Regulation (the “GDPR”). We endeavor to act in accordance with all applicable provisions of the GDPR. In this context, please note that you are entitled to receive access to your information, to correct or erase incorrect information, and to withdraw your consent to having your personal data stored and used by us. You understand that the data we store, collect, and process about you is necessary to conduct our operations and facilitate your participation in our programs, including but not limited to information required to ensure eligibility and to prevent repeat participation in our programs, as well as for other legitimate purposes allowed under the GDPR. If you are a European national and you wish to make such a request you may contact us by using the contact information in the “Privacy Questions” section at the bottom of this Policy.

11. Accessing or Updating Your Personal Information – You may request access to your personal information or correct and error or omission in your personal information by contacting us at information@birthrightisrael.com or write us at: Birthright Israel North America, P.O. Box 5892, Hicksville, NY 11802. We will make good faith efforts to resolve requests to correct inaccurate information except where the request is unreasonable, requires disproportionate technical effort or expense, jeopardizes the privacy of others, or would be impractical.

12. Modification of the Policy – We will occasionally update this Policy. When we post changes to this Policy, we will revise the "Effective Date” at the top of this Policy. We recommend that you check this Policy from time to time to inform yourself of any changes in this Policy.